National Taxpayer Advocate Nina Olson has issued her annual report on the most frequently litigated tax issues: Internal Revenue Code § 7803(c)(2)(B)(ii)(X) requires the National Taxpayer Advocate to identify the ten tax issues most often litigated in the federal courts, classified by the types of taxpayer affected. Through analysis of these issues, the National Taxpayer Advocate [...]

Did you ever wonder why the IRS prevails in trials before the United States Tax Court in 9 out of 10 cases. The more paranoid among attribute the government’s lopsided success rate to a silent conspiracy between the Court and the government. But the truth is more benign. More than 80% of all Tax Court cases [...]

Tax Court is a Prepayment Forum of Dispute Resolution Tax Court jurisdiction is conferred by a timely filed petition challenging the IRS’s Notice of Deficiency. The taxpayer is not required to first pay the tax and then sue for a refund as is required to confer jurisdiction on a United States’ District Court. This allows [...]